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Master File: What is it and Who Must Submit it

What is the Master File?

Royal Decree 634/2015 of July 10 – approving the Corporate Income Tax Regulations – and Law 27/2014 contain the specific documentation on related-party transactions or transfer pricing in Spain required by the Spanish Tax Authorities and to which taxpayers must adhere.

The Master File is one of the documents required by the Spanish Tax Authorities in transfer pricing matters. The master file should provide an overview of the MNE group business, including the nature of its global business operations, its overall transfer pricing policies, and its global allocation of income and economic activity in order to assist tax administrations in evaluating the presence of significant transfer pricing risk

What information should the Master File contain?

Art. 15 of the Spanish CITR sets the contents that the Group TP documentation should include. The information required in the Master File provides a “blueprint” of the Multinational Entity (MNE) group and contains relevant information that can be grouped in five categories:

Corporate structure and information on the Group’s organization:

  • Corporate and organizational structure of the Group.
  • Identification of related entities that undertake controlled transactions affecting the taxpayer.

Activities of the Group:

  • A general description of the Group’s activities, description of the main geographic markets in which they operate, source of profit and value chain of the services and goods which represent at least 10% of the net Group’s revenue during the FY.
  • Description of the functions performed, risks assumed, and main assets owned by the different Group entities, including changes compared to the previous FY.
  • A description of the Group’s intercompany TP policy, which includes the method(s) used in order to determine the prices adopted by the Group.
  • Brief description of any service arrangements and/or cost sharing agreements entered between Group entities.
  • A description of any restructuring and acquisitions or licensing of relevant asset occurred during the fiscal year.


  • A description of the Group’s strategy with respect to the development, property and exploitation of intangible assets, including the localization of the main facilities where any R&D activities are conducted, plus the management of those activities.
  • List of intangible assets relevant to TP, indicating its ownership and TP policy.
  • Amounts derived from the intragroup transactions involving the use of intangible assets, including the entities involved and their country of residence.
  • List of all agreements related to intangibles, including, the cost sharing, main R&D services or license agreements.
  • General description of any intangible transfer during the tax year, incorporating the entities, countries and amounts involved.

Financial and funding:

  • General description of the Group’s financing from third parties, including the main financing agreements signed with unrelated lenders/parties.
  • Identification of any members of the Group that provide/perform any financing functions/activities for the Group entities, including their country of incorporation, plus their place of effective management.
  • General description of the TP policy with respect to the intercompany financial agreements.

Financial and Tax position of the Group:

  • Group’s annual financial report, with consolidated financial statements.
  • List and brief description of the Group’s existing advance pricing agreements (APAs) and other tax rulings relating to the allocation of income among countries

Who must submit the Master File?

From a Spanish TP perspective, turnover is the indicator to be taken into consideration when preparing this documentation. The obligation to hold the Master apply to groups with a consolidated turnover higher than 45 million euros. There is no filing deadline; it should be available for the tax authorities by the end of the voluntary period for filing the CIT return.

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